Debit Card Dispute

A customer has filed a debit card dispute for a transaction in April of this year. She had ordered a signed copy of a Stephen King book from a merchant from whom she received a monthly subscription box. The Stephen King book was a special offer by the merchant. She never received the book and since June has been having difficulty getting her other shipments and has never received the Stephen King book. She discovered recently that the merchant never received permission to offer a signed Stephen King book, but they will not refund her charge (or even respond to her at this point). What are the bank's responsibilities under Reg E and under Visa? I am working to see if the customer has any documentation to show an original ship date as for chargebacks we are outside the normal 120 period. Thanks.

For the transaction to be considered a Reg E error under 1005.11(a) the transaction must either be unauthorized or incorrect. In this instance, the customer authorized the charge and was charged the correct amount so Reg E does not apply.

The 120 days clock for VISA either starts ticking from the date of the transaction or the promised delivery date whichever is later. The Bank does not have to file a chargeback until it is satisfied that the circumstances meet VISA's criteria. You do have a contractual obligation to assist the customer if they provide the documentation VISA requires to dispute the charge.


This is a great example of the types of questions I will be answering in my upcoming webinar next month.
VISA and Reg E Error Resolution

I am offering a similar session for Mastercard issuers.
Mastercard and Reg E Error Resolution

Had the consumer used a credit card and not a debit card there would be protections for a dissatisfaction of the product or service claim. But debit cards do not provide that. Brian is our V/MC rule expert on the assistance you must or can provide based on those rules, but that's not Reg E.

Thank you both.